United States Office of
Environmental Protection Emergency and
Agency Remedial Response
EPA/ROD/R07-93/069
September 1993
&EPA Superfund
Record of Decision:
Midwest Manufacturing/North Farm
(Operable Unit 2) (Amendment), IA
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4.
50272.101
REPORT DOCUMENTAll0N 11. REPORT NO.
PAGE EPA/ROD/R07-93/069
TItle and SubtIU8
SUPERFUND RECORD OF DECISION
Midwest Manufacturing/North Farm (OU2) (Amendment), IA
Second Remedial Action - Final
A~horts)
~
3. Rec1pIent's Accaslon No.
~
Report Oat,
09/29/93
6.
7.
8.
Performing Organization Repl. No.
9.
Performing Organization Name and Add,..
10
Project TuklWork Unit No.
11. Contrac:l(C) or Grant(G) No.
(C)
(G)
12. Sponsoring Organization Name and Addl'8Ss
U.S. Environmental Protection
401 M Street, S.W.
Washington, D.C. 20460
13. Type of Report. Period Cove.
Agency
800/800
14.
15. Suppl8m8ntary Not-
PB94';'9643~~
1&. Abstract (Um1t: 200 words)
The 8-acre Midwest Manufacturing/North Farm (Operable Unit 2) site includes the
.inactive Midwest Manufacturing electroplating and painting facility located in Kellogg,
Jasper County, Iowa. Land use in the area is predominantly industrial, with the North
~kunk River forming the south-southwes~ern boundary of the site. In addition, the site
lies within the 100-year floodplain of the North Skunk River and overlies an alluvial
aquifer. From 1973 to 1981, the current site owner, Smith Jones~ Inc., operated an
electroplating and painting facility at the Midwest Manufacturing OU. Chemicals used
in these processes included VOCs such as TCE, and metals such as cadmium, nickel, and
zinc. Prior to 1977, electroplating waste containing heavy metals, TCE, and paint.
residue from the onsite painting operations was discharged directly to North Skunk
River. In 1977, the State required treatment of wastewater to precipitate out the
metals prior to disposal. To comply with this requirement, Smith-Jones constructed an
onsite wastewater treatment system. From 1977 to 1978, the resultant sludge from this
system was periodically transported to the North Farm OU3 for disposal. From 1978
until 1981, an onsite disposal. trench received the sludge generated by the treatment
'plant. During the 1980s, EPA inspections revealed elevated heavy metal concentrations
(See Attached Page)
17. Docu.".,. Analyala .. Daseriptors
Record of Decision - Midwest Manufacturing/North Farm (OU2) (Amendment), IA
Second Remedial Action - Final
Contaminated Media: soil, gw
Key Contaminants: VOCs (PCE, TCE, toluene, xylenes), other organics (PARS),
(arsenic, chromium, lead), other inorganics (cyanide)
metals
b.
ld8nIlfiara/Op8noEndad Terms
Co
COSA11 FlaldlGroup
18. Availability Statement
19. Security CIaa (11118 Report)
None
3). Security aus (This PalJll)
None
21. No. of P81J118
39
%L Prtc8
(SM ANSI-Z39.18)
SHlnstlUCtion. on R.I/.,..
OP11ONAL FORM 272 (4-77)
(Fonnarly NTIS-35)
Department of Comman:e
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EPA/ROD/R0'7-93/069
Midwest Manufacturing/North Farm (OU2)
Second Reml~dial Action - Final
(Amendment), IA
Abstract (Continued)
in the disl)Osal trench, the surrounding soil, a 7,200-ft3 waste metals pile, and a borrow
pit area, as well as contamination of the alluvial aquifer. A 1990 ROD addressed both
source con1:rol and ground water and provided for capping of the disposal trench and
treatment ()f ground water using filtration and air stripping; however, the selected remedy
was never i~lemented. This ROD amends the 1990 ROD based on the information gathered
during pre--design activities. After EPA re-evaluated the site risks posed by OU2, it was
determined that only future exposure pathways resulted in unacceptable risk levels. In
addition, cl 1991 pump test revealed that the alluvial aquifer is less permeable than the
previous data had indicated, thereby, lengthening the ground water remediation time and
increasing the remedial costs. The primary contaminants of concern affecting the soil and
ground water are VOCs, including PCE, TCE, vinyl chloride, toluene, and xylenes; other
organics, i.ncluding PARs; metals, including arsenic, chromium, beryllium and lead; and
. other inorganics, including cyanide.
The selected remedial action for this site includes monitoring ground water; and
implementing institutional controls, including deed restrictions, and site access
restrictions, including a perimeter fence, to prevent exposure to contaminants in
The estimated present worth cost for this remedial action is $118,530.
soiL
PERFORMANCE STANDARDS OR GOALS:
MCLs for contaminants of potential concern will not be exceeded in selected monitoring
wells or in supply wells.
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DECLARATION
RECORD OF DECISION AMENDMENT FOR THE
MIDWESTMANUFAcruRiNG/NORTH FARM SITE
NORTH FARM OPERABLE UNIT
MIDWEST MANUFAcruRING OPERABLE UNIT
JASPER COUNTI
KELLOGG, IOWA
SEPTEMBER 1993
SITE NAME AND LOCATION
Midwest Manufacturing/North Farm Site
North Farm Operable Unit
Midwest Manufacturing Operable Unit
Kellogg, Iowa
STATEMENT OF BASIS AND PURPOSE
This decision document, together with a Record of Decision (ROD) dated
September 30, 1988 for the North Farm Operable Unit and a ROD dated September 27,
1990 for the Midwest Manufacturing Operable Unit, presents the selected remedial
actions for the North Farm Operable Unit and the Midwest Manufacturing Operable
Unit which together comprise the Midwest Manufacturing/North Farm Site, Kellogg,
Iowa. These actions were chosen in accordance with the Comprehensive Environmental
Response, Compensation and Liability Act of 1980 (CERCLA), as amended by the
Superfund Amendments and Reauthorization Act of 1986 (SARA), and to the extent
practicable, the National Contingency Plan (NCP). These decisions are based on the
administrative records for these Operable Units.
The United States Environmental Protection Agency (EP A) is the lead agency for
the site, and the Iowa Department of Natural Resources (IDNR) has been designated
the support agency. This ROD amendment is being issued by the EP A. The State of
Iowa concurs on the amended selected remedies.
DESCRIPTION OF THE AMENDED SELECTED REMEDIES
NORTH FARM OPERABLE UNIT
The major components of the selected remedy, as now amended, include:
SOIlS
Deed restrictions will be implemented to prevent using the disposal area as
a vegetable garden which could lead to accidental exposure to hazardous
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substances. No action would be taken to remove or control the migration
of the contaminants at the site.
GROUND WATER
Deed restrictions will be implemented to prevent the installation of a water
supply well which would be used for human consumption. Ground water
monitoring will be conducted to verify that the remedy remains protective
of human health and the environment and that no future unacceptable
exposures to contaminants at this Operable Unit occur.
MIDWEST MANUFACTURING OPERABLE UNIT
The major components of the selected remedy, as now amended, include:
SOILS
A perimeter fence will be installed to control access to the disposal areas
located at the Midwest Manufacturing Operable Unit. Deed restrictions
will be placed on the property to prevent any changes in land usage. These
restrictions will limit any future exposure to hazardous substances which
remain on-site.
GROUND WATER
No action will be taken to remove and/or otherwise control the migration
of the contaminants within the ground water at the Operable Unit. Deed
restrictions will be implemented to prevent the installation of a water
supply well which would be used for human consumption. A survey of all
water supply wells, both public and private within one mile of the plant
site, will be conducted prior to initiating the monitoring program. Two new
monitoring wells will be installed in locations close to existing public water
supply wells. Ground water monitoring will be conducted to verify that the
remedy remains protective of human health and the environment and that
no future unacceptable exposures to contaminants at this Operable Unit
occur.
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STATUTORY DETERMINATIONS -
MIDWEST MANUFACTURING/NORTH
FARM SITE
The selected amended remedy for each Operable Unit is protective of public
health, welfare and the environment, complies with federal and state applicable or
relevant and appropriate requirements, and is cost-effective. The amended remedy for
each Operable Unit does not satisfy the preference for remedies that employ treatment
which permanently and significantly reduces the volume, toxicity, or mobility of hazardous
materials as a principal element. In addition, the remedy for each Operable Unit does
not utilize permanent solutions or alternative treatment technologies (or resource
recovery technologies) to the maximum extent practicable.
Because each remedy will result in hazardous substances remaining at the North
Farm Operable Unit and at the Midwest Manufacturing Operable Unit above health-
based levels, a review of each Operable Unit remedy will be conducted within five years
after commencement of these remedial actions to ensure that each specific Operable
Unit remedy continues to provide adequate protection of human health and the
environment.
Date d~O't /9'73
~ >I;:~i:y
' il1iam~. i
..j{r/: ActingLRegional Administrato
Region VII
Attachments:
Decision Summary
Responsiveness Summary - Attachment A
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AMENDED RECORD OF DECISION
DECISION SUMMARY
MIDWEST MANUFACTURING/NORTH FARM SITE
NORTH FARM OPERABLE UNIT
MIDWEST MANUFACTURING OPERABLE UNIT
KELLOGG, lOW A
Prepared by:
U.S. Environmental Protection Agency
Region VII
Kansas City, Kansas
September 28, 1993
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Section
I.
II.
III.
IV.
V.
Amended Record of Decision
Decision Summary
Contents
Page
wca tion and Descri pti on... ............ ....... ........... ................. ................. .............1
Community Relations[[[2
Reasons for Issuing the Record of Decision Amendment........................2
a.
b.
N orth Farm Operable U ni 1.... ........... ............................... ........ .... ......2
Midwest Manufacturing Operable Unit...........................................5
Description of the Original and Amended Remedies.................................9
a.
b.
N orth Farm Operable U nit[[[ 9
Midwest Manufacturing Operable U ni t...........................................1 0
Comparative Analysis of the Original and Amended Remedies.............12
a.
b.
North Farm Operable U ni t........................................... ........ ............13
Midwest Manufacturing Operable U nit........................................... 17
VI.
. Statutory Determinations. ............. ............... .................. ....... ........ ........ ..........21
a.
North Farm Operable Unit
1. Ground Water. .................... ........... ........ ............. ....... ..............21
2. Soils................. [[[ 21
b.
Midwest Manufacturing Operable Unit
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List of Figures:
List of Tables:
Decision Summary
Contents
1.
Site Vicinity Map
2.
Site Locator Map
3.
City Wen Location Map
1.
North Farm Contaminants of Concern/Health Risk in both Ground Water
. and Contaminated Soils
2.
North Farm Summary of Future Risk
3.
Exposure Scenarios Quantified at the Midwest Site
4.
Summary of Carcinogenic Risk
5.
Chemicals of Potential Concern
6.
Summary of Subchronic Noncarcinogenic Health Hazards
7.
Summary of Chronic Noncarcinogenic Health Hazards
Responses Received on Proposed Plan
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DECISION SUMMARY
RECORD OF DECISION AMENDMENT
MIDWEST MANUFAcruRING/NORTH FARM SITE
NORTH FARM OPERABLE UNIT
MIDWEST MANUFAcruRING OPERABLE UNIT
I. LOCATION AND DESCRIPTION
The Midwest ManufacturingINorth Farm Superfund Site consists of two non-
contiguous pieces of property known as the North Farm Operable Unit and the Midwest
Manufacturing Operable Unit. The North Farm Operable Unit is located 2 miles north
and 1/2 mile east of Kellogg, Iowa. Kellogg, population 700, is located in Jasper County,
which is approximately 42 miles east of Des Moines (See figure 1). The Midwest
Manufacturing Operable Unit is owned and operated by Smith Jones, Inc., Midwest
Division and is located at 101 High Street in the city of Kellogg, Iowa. The Midwest
Manufacturing Operable Unit occupies eight acres within the North Skunk River
floodplain (see figure 2).
Smith Jones, Inc. engaged in electroplating and painting operations of
manufactured products from 1973 until 1981. The electroplating process involved the use
of trichloroethylene (TCE) to clean the product before it was coated with a metal.
Cadmium was used as the metal coating prior to 1979, nickel was used until 1980, and
from 1980-1981 zinc was used. Prior to 1977, electroplating wastes containing TCE,
heavy metals, and paint residue generated from on-site painting operations were disposed
directly into the North Skunk River. In 1977, a wastewater treatment system was
constructed. Sludges generated from the treatment process were pumped to a storage
tank where they were periodically removed and placed into one of two disposal areas.
Electroplating operations ceased in June of 1981.
From 1977 to 1978, the sludge resulting from this wastewater treatment process
was periodically transported to the North Farm Operable Unit for disposal. The sludge
was placed in an unlined trench excavated to a depth of approximately five feet below
ground surface. A berm was initially placed around the perimeter of the trench to divert
surface water away from the disposed material. The trench was covered with native soils
in 1978.
The disposal trench at the Midwest Manufacturing Operable Unit, located on the
main plant pmperty, received the sludges generated by the treatment plant from 1978
until June of 1981. The areas of disposal at the Midwest Manufacturing Operable Unit
include the waste disposal trench, the buried waste met~l pile and the marsh.
Greater detail concerning the characteristics of each Operable Unit and the prior
investigation and remedial alternatives may be found in the administrative records for
each Operable Unit.
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II.
COMMUNITY RELATIONS
The United States Environmental Protection Agency (EPA) is issuing this Record
of Decision (ROD) Amendment to meet public participation provisions mandated under
Section 117(a) of the Comprehensive Environmental Response, Compensation, and
Uability Act (CERCLA) as amended by Superfund Amendments and Reauthorization
Act (SARA) of 1986, and Section 300.435 (c)(2)(II) of the National Oil and Hazardous
Substances Pollution Contingency Plan (NCP).
The Proposed Plan for this ROD Amendment was made available to the public in
the administrative record file located at the Kellogg, Iowa City Hall and the EP A Region
VII Office, Kansas City, Kansas. A public notice was published in The Newton DaHy
News on February 19, 1993, announcing the commencement and length of the public
comment period and the availability of the administrative records file at the Kellogg City
Hall.
Fact sheets were also mailed to area residents, local officials and the media
announcing the availability of the project documents and the public comment period.
EP A offered to hold a public meeting to discuss the Proposed Plan for the
Amended ROD if requested. No requests were received.
Comments received during the public comment period are addressed in the
Responsiveness Summary.
III.
REASONS FOR ISSUING THE ROD AMENDMENT
NORTH FARM OPERABLE UNIT
REASSESSMENT OF SITE RISKS
EP A has reevaluated the site risks posed by the North Farm Operable Unit. This
reevaluation included a review of the information contained within the ROD, as well as
other information EP A has obtained concerning the North Farm Operable Unit. .
Section V of the ROD identified the following site characteristics: Onsite surface
soils are contaminated with various levels of heavy metals such as calcium, cadmium and
manganese. The contaminated soil within the disposal cell contains various levels of
heavy metals such as cadmium, nickel, .zinc, sodium, cyanide and calcium. This material
failed the EP Toxicity test for cadmium. According to the Public Health Evaluation,
cadmium bioaccumulates in mammals, particularly in the kidney and liver. Sub-chronic
and chronic exposures to cadmium are associated with a number of noncarcinogenic but
toxic effects, including kidney damage in humans and experimental animals. Non-
carcinogenic toxic effects may result from incidental ingestion of soil, ground water or
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other media. EP A considers cadmium a carcinogen only when inhaled. The ground
water beneath the site appears to be a perched water table that has no hydraulic
continuity with the Bear Creek alluvium. The ground water health based action level for
cadmium is 18 micrograms/liter (ugll) and for manganese is 7700 ugll. .
Cadmium and manganese were identified as chemicals of concern for the ground
water media. Cadmium and cyanide were identified as chemicals of concern for the
contaminated soil media. Table 1 presents the site information regarding the levels of
contaminants present in the soils and ground water and the health based action level for
these contaminants per exposure pathway. No carcinogens are present at the North
Farm Operable Unit, therefore only non-carcinogenic risks are evaluated. The health
based action level is the contaminant concentration level above which adverse health
effects may be experienced by persons exposed to the contaminant.
Under current land-use conditions at the North Farm Operable Unit, there are no
complete exposure pathways by which human receptors could be exposed to site
contaminants. The site is relatively isolated. The nearest residence is one mile away. Of
the chemicals, only cadmium may be of concern under future-use scenarios. All others
are considered insignificant.
The exposure scenarios considered for possible future land-use conditions are:
1.
2.
3.
Ingestion of ground water;
Direct contact with (incidental ingestion of) surface soils; and
Ingestion of contaminated vegetables.
Average and plausible maXimum exposure scenarios were developed for each of
these pathways. The exposure point concentrations of cadmium were estimated for the
potentially exposed populations. Human health risks were assessed based on these
estimates of exposure and a quantitative description of cadmium's toxicity.
The 1988 ROD concluded the following "It is determined that no action needs to
be taken to protect ground water with respect to cadmium." Cadmium received a hazard
index score equal to one, which indicates that it represents a marginal risk to humans
who may ingest cadmium contaminated water. The health based action level for
cadmium in water is 18 ug/l. This is 1 uglliess than the highest total concentration level
found at the site. Only one ground water sample from the monitoring wells was found to
contain cadmium. The ground water sample containing cadmium was not filtered prior
to analysis, so the analytical results represent the total cadmium present. None of the
filtered ground water samples, which represent the dissolved cadmium concentration,
exceeded the action level. Monitoring wells are typically of a different type of
construction than wells constructed for drinking water. Monitoring wells usually produce
a greater amount of sediment mixed with water than is the case for a drinking water well.
Inorganic contaminants have a tendency to attach themselves to the sediment. This
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causes the contaminant concentration measured in an unfiltered (total) sample to be
greater than that of a filtered sample. Therefore, the unfiltered contaminant
concentration measured in a drinking water well would be similar to that measured in a
mtf:red sample collected from a monitoring well. Cadmium, therefore, would not
represent a potential human health threat at its current concentration level.
The ground water at the North Farm Operable Unit lacks any connection to other
off.site ground water zones. A drinking water well located in this water table would only
produce from 0 to 1 gallon per minute (gpm). This amount is significantly below most
resi.dential needs. EP A's remedies require the collection of ground water samples from
the monitoring wells present at the North Farm Operable Unit. EP A will use the
information gained from the ground water monitoring program to detect any changes in
the levels of contaminants present in the water table at this site.
Table 2 is a summary of non-carcinogenic risk for human exposure to cadmium at
the Nonh Farm Operable Unit. "CDI:RfD" is the chronic daily intakes or the Reference
Dose for the individual compound in units of milligrams per kilogram of body weight per
day (mg/kglday). The "average case" is based upon geometric mean concentrations of
contaminants used together with the most likely exposure conditions. The "plausible
maximum case" is based upon the highest concentrations of contaminants used together
with high estimates for the exposure conditions. For the "plausible maximum case," one
exposure route presents a risk greater than 1 (> 1), that is the route for ingestion of
vegetables grown in the contaminated soils. Ingestion of ground water contaminated
with cadmium present at a concentration of 19 ugll has a risk equal to 1. As a "plausible
maximum case," these exposure routes are considered remote. Deed restrictions limiting
land use can prevent all future exposure scenarios evaluated. No one is currently
growing vegetables in the disposal cell at the North Farm Operable Unit nor is anyone
drinking the water at the site. Monitoring of the quality of the ground water at the site
will enable EP A to determine if EP A's selected remedy is protective of human health
and the environment.
As stated in the 1988 ROD, EP A has concluded that the site, in its present
conditions, poses no current risk to human health and the environment. However,
certain future risks do exist if no action is taken. Future risks can be prevented by using
institutional controls which would prohibit certain future land use, such as vegetable
gardening, and prevent the installation of a water supply well.
Exposures to Wildlife
Section 6.7.4 of the Remedial Investigation (RI) Repon assessed the site risks to
wildlife and concluded the following: "Terrestrial and avian species foraging at the site
may be exposed to contaminants in the soil. Most animals, though, especially avian
spc~cies, forage. over a large range area relative to the size of this site. Thus, it is very
unlikely that significant adverse effects at either a population or an individual level wilJ occur."
4
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APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL
REGULATIONS (ARARs)
In 1988, a variety of federal environmental laws were reviewed as to legal
applicability or relevance and appropriateness to the remedial alternatives under
consideration. Requirements under the Resource Conservation and Recovery Act
(RCRA), as amended, and the Hazardous and Solid Waste Amendments (HSWA) of
1984 were found to be potentially applicable or relevant and appropriate to these
remedial alternatives. Review of various State environmental laws and regulations,
including those pertaining to solid and hazardous waste management, indicate that the
Federal environmental laws are at least as or are more stringent than State Law.
RCRA, as amended by HSW A of 1984, regulates the. generation, transportation,
treatment, storage and disposal of defined hazardous waste. In the 1988 ROD for the
North Farm Operable Unit, the remedy selected for the contaminated soils onsite was
excavation and treatment with off-site disposal. This activity would have involved the
generation of hazardous waste and thus, RCRA was designated as an ARAR. However,
the amended remedy will result in the contaminated soils remaining undisturbed at the
subsite; therefore, no generation of hazardous waste will occur and RCRA will no longer
be an ARAR.
There are no federal or state ARARs for the selected remedies, institutional
controls.
OTHER CONSIDERATIONS
Iowa Code Section 455B.426 identifies and lists sites where the disposal of a
"hazardous waste" or "hazardous substance" occurred at the site either illegally or prior to
regulation under Chapter 455B. The state of Iowa has notified EP A that the North
Farm Operable Unit is listed on the "Registry of Hazardous Waste or Hazardous
Substance Disposal Sites and Hazardous Waste Remedial FundI! Annual Report - 1992.
According to the State, site use cannot change due to this listing.
MIDWEST MANUFAcruRiNG OPERABLE UNIT
REASSESSMENT OF SITE RISK
EP A has reevaluated the site risks posed by the Midwest Manufacturing Operable
Unit by reviewing the information contained within the ROD, as well as other
information EP A has obtained during pre-design activities conducted at the Midwest
Manufacturing Operable Unit.
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EP A reviewed Appendix 8 of the RI Report, Baseline Risk, and Section VIII of
the 1990 ROD to review the risks at the Midwest Manufacturing Operable Ur.it. The
foHowing is the summary of this review.
A list of chemicals present at the site was compiled. Chemicals were eliminated
from the risk assessment if they were not detected in environmental samples, were
detected infrequently, were common laboratory contaminants or if they were chemicals
that were essential nutrients (and therefore relatively non-toxic). After exclusion of such
chc::micals, twenty-six chemicals were selected as contaminants of potential concern.
These chemicals are presented in Table 5.
An exposure assessment analyzes two factors that affect the quantification of risks:
potentially exposed populations and exposure pathways. In general. Superfund Exposure
Assessments consider both current and future exposure scenarios.
Current human populations that potentially may be exposed on the Midwest
Ma.nufacturing Plant Site are occupational workers of the Smith Jones plant and
trespassers. There are no off-site populations that would potentially be exposed to the
contaminants of concern. Results of the risk assessment determined that the site, in its
current conditions, poses no unacceptable health risk.
Currently, the Smith Jones property is zoned for industrial use and a county
orc.inance prohibits residential construction on a floodplain. Therefore, it was assumed
that any future development would be industrial in nature and future onsite populations
would be engaged in similar occupational activities as current ones. Future occupational
workers could be exposed via contaminated drinking water if a well was drilled onsite.
Future offsite residential populations are assumed to be the same statistically as current
populations. These populations could be exposed to contaminated drinking water if a
drinking water well were installed into a plume that originated from the site.
Ten exposure pathways were selected for further quantitative evaluation from a
list of 27 exposure pathways presented in the Risk Assessment report. These ten were
selected because they were thought to present the highest potential for adverse health
eff<:cts resulting from site exposures.
Current routes with the highest exposure routes were all related to contaminated
soils and wastes. No ground water exposure routes were evaluated since this route is not
complete. The baseline risk assessment report did not identify any current human health
risks posed by the site.
For the evaluation of the future potential exposure routes, seven future potential
exposure routes were evaluated in the Risk Assessment report. Exposure scenarios are
listed in Table 3 with the individuals exposed, routes and media identified.
6
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Table 4 is a summary of the carcinogenic risk posed by the site. Only future risks
were found to be of concern. Onsite workers may experience a slight increase in excess
cancer risk from contact with contaminants arsenic, beryllium and vinyl chloride in soil
and a greater risk (a one in one thousand) from ingestion of the same contaminants in
the ground water, if an onsite water supply well was installed onsite and provided
contaminated water for consumption. The presence of both arsenic and beryllium in the
ground water is not a result of plant activities since these contaminants were present both
on-site and off-site and therefore, are considered to be naturaHy occurring.
Vinyl chloride was present in 4 out of 26 ground water samples, twice in one well
at a level of approximately 40 ug/l. The Maximum Contaminant Level (MCL)l for vinyl
chloride is 2 ug/l. The only potential exposure route of concern is that of the ingestion of
contaminated ground water.
. Future site risks can be prevented through the use of "institutional controls" such
as deed restrictions which would limit land use and development and would prevent the
installation of a water supply we1l2 and access restrictions which would prevent access to
the waste disposal areas and prevent the exposure of the trespasser to the hazardous
wastes which remain on-site. A perimeter fence would prevent dermal exposure to any
soil contaminants. A ground water monitoring program, for any supply wells, either
public or private, within a one mile radius of the site, will be used to determine the
presence of any contaminants within the area water supply.
Table 5 lists the twenty-six chemicals which were selected as contaminants of
potential concern of which three, arsenic, beryllium and vinyl chloride were determined
to be indicative of on-site contamination. Populations that maybe potentially exposed to
on-site contaminants are occupational workers of the Smith Jones plant and site
trespassers. There is no current off-site exposure. The levels of contamination present
at the site are not expected to cause adverse health effects.
Tables 6 and 7 present a summary of the sub-chronic non-carcinogenic health
hazards associated with the Midwest Manufacturing Operable Unit and a summary of the
chronic non-carcinogenic health hazards associated with the Midwest Manufacturing
Operable Unit, respectively.
1 The Maximum Contaminant Level or MCL is the level at which a contaminant can
be present within the ground water without causing adverse effects.
2 Deed restrictions which limit land use are sometimes referred to as "use
restrictions."
7
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Exposures to Wildlife
Section IX of the 1990 ROD stated the following: "An ecological assessment was
conducted to determine if there are any adverse effects occurring or likely to occur in
aquatic organisms, populations or communities exposed to contaminants originating from
the site. Three river sediment samples were collected at an upstream and at a
downstream location from the site, for a total of six sediment samples. Analysis of these
samples did not indicate the presence of metals at concentrations that would pose an
adverse threat to aquatic organisms. This conclusion is further supported by the results
obtained from analysis of two biological samples collected from an upstream and a
downstream location from the site. Analysis of these two samples indicated that there
was no uptake of metals by these organisms.
No federal or state critical habitats, endangered wildlife or natural resources are
potentially threatened or damaged as a result of past waste disposal practices conducted
at the site."
NEW SITE DATA
In December, 1991, EPA conducted a pump test. The information gained from
this test indicated that the aquifer is less permeable than previous data indicated. This
lack of aquifer permeability lengthens the ground water remediation time from 25 years
to .35 years which, in turn, increases the overall cost of the extraction and treatment
component of the 1990 ROD. EP A's preliminary design also included an increase in the
number of extraction wells from 5 to 8 as necessary for site remediation.
APPLICABLE OR RELEVANT AND APPROPRIATE ENVIRONMENTAL
REGULATIONS (ARARs)
In 1990, a variety of federal environmental laws were reviewed as to legal
applicability or relevance and appropriateness to the remedial alternatives under
consideration. Requirements under RCRA, as amended, and HSW A of 1984 were found
to be potentially applicable or relevant and appropriate to the hazardous sludge present
at the site. The State of Iowa provided a list of its statutes that may be applicable or
relevant and appropriate to this site. Chapter 133 of the Iowa Administrative Code was
one statute identified which provided more stringent requirements than the federal law.
RCRA, as amended by HSW A of 1984, regulates the generation, transponation,
treatment, storage and disposal of defined hazardous waste. In the 1990 ROD for the
Midwest Manufacturing Operable Unit, the remedy selected for the contaminated soils
onsite was installation of a landfill cap of the waste disposal area and extraction and
tre:atment of the contaminated ground water. These activities would have involved the
generation of hazardous waste and thus, RCRA was designated as an ARAR. However,
thc~ amended remedy will result in the contaminated soils and ground water remaining
8
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undisturbed at the subsite; therefore, no generation of hazardous waste will occur and
RCRA will no longer be an ARAR.
For the contamination present in the ground water, in 1990, the state of Iowa
determined that "active" cleanup, that is extraction of the contaminated ground water
with treatment to meet MCLs was necessary to meet the criteria of Chapter 133. In
1993, the State of Iowa expressed to EPA its position regarding Chapter 133 of Iowa's
Code that "passive cleanup" satisfies the state's ARAR. "Passive cleanup" entails leaving
the contamination in the ground water and allowing natural processes to remediate the
site. This is also referred to as "natural attenuation." The selected amended remedial
alternative would meet this state ARAR.
OTHER CONSIDERATIONS
Iowa Code Section 455B.426 identifies and lists sites where the disposal of a
"hazardous waste" or "hazardous substance" occurred at the site either illegally or prior to
regulation under Chapter 455B. The state of Iowa has notified EP A that the Midwest
Manufacturing Operable Unit is listed on the "Registry of Hazardous Waste or
Hazardous Substance Disposal Sites and Hazardous Waste Remedial Fund" Annual
Report - 1992. According to the State, site use cannot change due to this listing.
IV.
DESCRIPTION OF ORIGINAL REMEDIES AND AMENDED REMEDIES
NORTH FARM OPERABLE UNIT
The ROD for the North Farm Operable Unit addresses the contaminated soils
present within the disposal cell. The original ROD requires excavation of the
contaminated soils within and around the disposal cell that contains cadmium
concentration levels exceeding a health based action level of 13 milligrams per kilogram
(mglkg). The excavated soil would then be treated using stabilization technology to the
point where that the leachate contaminant concentrations no longer exceed established
criteria. After treatment, the excavated soil would be disposed into a permitted RCRA
Subtitle C disposal facility. The excavated area must be backfilled and graded with clean
soil to support a vegetative cover. This remedy represents RCRA's Landfill Clean
Closure Option as defined in 40 CFR Part 264, Subpart N, and therefore, requires no
long-term monitoring or deed restrictions. The 1988 ROD estimated the cost for the
total project to be $220,185. In 1993, total project costs are now estimated at
approximately $403,000. Increase design costs (from approximately $51,000 to
approximately $160,000) contributed the largest share of the increased costs. Also, cost
for the transportation and disposal of the waste significantly increased.
The response action now being selected for the North Farm Operable Unit is
'what was described as the "No Action" alternative in the 1988 ROD, with the addition of
ground water monitoring and deed restrictions. Under this remedy, no specific response
9
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acticn would be taken to remove the contaminants at the site or control their migration
from the site. Deed restrictions, placed on the property, would prevent the installation of
a water supply well and the use of the disposal cell area as a vegetable garden. The
deed would also state that hazardous substances remain at this site. Project costs are
estimated to be $27,100 ($10,400 for the first year [sample 3 ground water wells
quarterly] plus costs for deed restrictions. $15,300 Present Worth estimate for years 1-4
with semi-annual sampling events, collection and analysis costs for each water sample
wen: estimated to be $665 per sample with a 30% contingency at an 8% interest rate.
Cost: for deed restrictions are estimated to be $1,454.
EP A's response action will include the collection of ground water samples from
the three existing ground water monitoring wells at the North Farm Operable Unit.
Analytical results from these ground water samples will be evaluated to aid. EP A in
verifying that no unacceptable exposures are occurring. During the first year of
monitoring, ground water samples will be collected quarterly and analyzed for both total
and dissolved metals. Once four consecutive quarters of data are available, EP A will
evaluate the information and determine the need to collect further samples. This
evaluation will focus on the levels of cadmium, zinc and nickel present in both the
dissolved and total samples. EP A will reduce the frequency of sampling if the data
indicates that the contamination present does not exceed drinking water standards for
cadmium, zinc and nickel3. If the analytical results indicate that contamination is
migrating from the North Farm Operable Unit, the sampling program will be expanded
to determine the rate and extent of migration and the response action at the North Farm
Operable Unit will be reevaluated. Because this remedy will result in hazardous
substances remaining on-site above drinking water standards, a review will be conducted
to t:nsure that this remedy continues to provide adequate protection of human health and
the environment within five (5) years after commencement of the remedial action.
MIDWEST MANUFACTURING OPERABLE UNIT
The original ROD for the Midwest Manufacturing Operable Unit addresses the
contaminated ground water and the contaminated soils in the disposal trench area. The
original selected remedy provides for ground water treatment and capping of the waste
disposal cell in accordance with the RCRA landfill closure and post-closure requirements
as described in 40 C.P.R. ~ 264 Subparts G and N. The design life of the cap is
estimated to be 30 years. Post-closure care requirements would include maintenance of
the final cover and maintenance of the ground water monitoring system. The total
project cost increased considerably from the 1990 ROD estimate of $488,844 to a current
3 The May 1993 drinking water standards and health advisories for the
contamination at the North Farm site are: cadmium 5 ug/l; nickel 100 ugll and zinc 500
ugll. Cadmium and nickel are MCLs. Zinc is a secondary maximum contaminant level,
which means that it is for aesthetics.
10
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estimate of $1,091,531. Increased design costs (from approximately $89,000 to
approximately $249,000) contributed the largest percentage share of the incre~sed costs,
Operation and Maintenance costs increased from an estimated $200,000 to an estimated
$460,000, and construction costs increased from an estimated $200,000 to an estimated
$310,000.
. The remedy now being selected for the Midwest Manufacturing Operable Unit is
described as Alternative #1 "No Action with Ground Water Monitoring" in the ROD of
September 1990 with the addition of a perimeter fence to limit access to the disposal
areas at the plant site. No specific response action will be taken to remove and/or
otherwise control the migration of the contaminants at the Operable Unit. Institutional
and engineering controls, such as deed restrictions and perimeter fencing will be
implemented. Deed restrictions will prevent the installation of a ground water supply
well thereby preventing the use of the contaminated on-site ground water. A long-term
ground water monitoring program wi11 be implemented. A private water well survey will
be conducted to identify all private water supply wells within one mile of the site. Any
private water wells identified through this survey will be included in the ground water
monitoring program.
Two new monitoring wells will be insta))ed, one off-site to the west of the property
between the site and the city water supply We)) No.2, and one in the northeast corner of
the property between the site and city water supply Well No.1 (see figure 3). These two
wells, in conjunction with four of the existing monitoring wells in the southern portion of
the site, the three public supply wells and any private water supply we))s identified within
the one mile radius of the site, wiJ) be sampled quarterly to track long-term changes in
the contaminant concentrations in ground water. Water samples wi11 be analyzed for
volatile organics and both total and dissolved metals. The water samples from these
wells will allow EP A to identify any tendency for contaminant migration towards the city
water supply wells, and will monitor the concentration of contaminants in on-site ground
water. Samples from the public supply system and any private supply wells will provide
information concerning the quality of the existing water supply.
After the collection and evaluation of the analytical results of the first round of
ground water samples, EP A may require the sampling of additional existing monitoring
wells. Once the ground water data base contains four consecutive quarters of data, EP A
will determine the sampling strategy for the next year. If data obtained from a ground
water monitoring well indicates that the ground water meets or does not exceed MCLs
for the chemicals of concern at the Midwest Manufacturing Operable Unit for two
consecutive sampling events, the monitoring well will then be sampled on an annual
basis. Once the water from a monitoring well meets the MCLs for two years, the well
will no longer be sampled. Water supply wells will be sampled quarterly for the first two
years. EP A and the State of Iowa will determine the long-term sampling frequency for
all water supply wells.
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Public access is somewhat restricted at the site perimeter. There is evidence that
the public can enter the site from the Holmdahl park area,and has used the area to ride
all terrain vehicles and other vehicles south of the plant site bordering the North Skunk
river. A perimeter fence must be installed to prevent public access to any of the disposal
areas which contain sludge from the past disposal activities. EP A has estimated the cost
of fencing to be $20 per foot, including design costs. EP A estimates that up to 400 feet
of fencing is needed and the cost of the fencing should be approximately $11,000 with a
30% contingency added. Maintenance of the perimeter fence is estimated to be less than
$1 OO/year.
Project costs for the implementation of the original remedy have increased to
$1,091,531, (up from 1990 ROD estimate of $488.844). The cost of the amended remedy
is estimated at $118,530 (Alternative 1 in ROD issued September, 1990 plus monitoring
of city supply wells quarterly for the first year which is 36 water samples at $665/sample
or $31,100 with a 30% contingency). Design, engineering and construction costs are
estimated to be approximately $47,000. Total present value of the monitoring costs for
years, 2-5 of the project are estimated to be $40,400 estimated at an 8% interest rate.
Fencing costs are estimated to be approximately $11,000. Cost of deed restrictions is
estimated to be $1454.
Because this remedy will result in hazardous substances remaining on-site above
health-based levels, a review will be conducted to ensure that this remedy continues to
provide adequate protection of human health and the environment within five (5) years
after commencement of the remedial action.
v.
COMPARATIVE ANALYSIS OF THE ORIGINAL AND AMENDED REMEDIES
The NCP sets forth nine evaluation criteria which serve as a basis for comparing
the remedial alternatives for final actions. The nine criteria are divided into three
categories: Threshold Criteria, Primary Balancing Criteria, and Modifying Criteria. If
any :remedial alternatives identified during the Feasibility Study do not meet the
Threshold Criteria (Criteria 1 and 2), EPA will not consider them as possible final
remedies. If the alternatives satisfy the Threshold Criteria, they then are evaluated
agai:r1st the next five criteria, called the Primary Balancing Criteria. These criteria are
used. to compare the remedial alternatives against each other in terms of effectiveness,
impJementability, and cost. The final two criteria, state acceptance and community
acceptance, are called Modifying Criteria. The alternatives are compared against the
Modifying Criteria after the state and the community have reviewed and commented on
the Proposed Plan and the other alternatives considered by EP A.
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NORTH FARM OPERABLE UNIT
The following is a discussion of the nine criteria used by EP A for remedy
selection.
A.
Threshold Criteria:
1.
OveralI Protection of Human Health and the Environment
EP A assesses the degree to which the alternatives would eliminate, reduce,
or control threats to public health and the environment through removal,
containment, and/or institutional controls. An alternative is normally
considered to be protective of human health if the excess cancer risk is
reduced to less than 1 in 1,000,000 (10-6) and risks do not pose non-
carcinogenic health risks {Hazardous Index (HI) < 1 }.4
The contamination at the North Farm Operable Unit poses no current risks
to human health or the environment. Future risks can be controlled by
institutional controls, that is, deed restrictions which wiJI be placed on the
property to prevent the installation of a ground water well and any
vegetable gardening in the disposal cell. Monitoring of the quality of the
ground water will assist EP A in determining if this action continues to be
protective of human health and the environment.
2.
Compliance with all Applicable or Relevant and Appropriate State
and Federal Environmental Regulations
EP A assesses whether the remedial alternatives being evaluated would
compJy with aJl applicable or relevant and appropriate requirements, called
ARARs, established by the state and federal government. The 1988 ROD
identified RCRA as relevant and appropriate for the soils removed from
the North Farm Operable Unit. The amended ROD leaves all soils in
place, therefore, RCRA is ~ot applicable to this action.
There are no federal or state ARARs for the selected remedy, institutional
controls. No chemical-specific, action-specific or location-specific ARARs
were identified for the implementation of the selected amended alternative.
4 The Hazardous Index rating does not exceed 1.
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B.
Primary Balancing Criteria:
1.
Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to the ability of a remedy
to maintain reliable protection of human health and the environment over
time once clean up goals have been met. Institutional controls, in the form
of deed restrictions, would prevent exposure to contaminants present at the
North Farm Operable Unit. These restrictions will apply to this property
regardless of any subsequent change in ownership, thereby offering long-
term effectiveness and permanence of the selected amended remedy. EP A
has no evidence that the levels of contamination at the site pose a current
risk to either human health or the environment. The amended remedy is
as protective as the original remedy since any future exposure to hazardous
substances will be prevented by its implementation. The amended remedy'
for the North Farm Operable Unit is preferable to EPA.
Since contamination will remain on-site, EP A will conduct a 5-year review
of this amended remedy to determine if it continues to be protective of
human health and the environment and remains effective in the long-term.
The selected amended remedy does not utilize permanent solutions or
alternative treatment technologies.
2.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Section 121(b) of CERCLA states that remedial actions involving
treatment, which permanently and significantly reduce the volume, mobility
or toxicity of hazardous materials, are to be preferred over those not
involving such treatment. This evaluation criteria relates to the ability of a
remedial alternative to control or eliminate risks caused by the mobility,
toxicity or volume of a hazardous waste. The proposed remedy would have
limited impact on the toxicity, volume or mobility of the hazardous
substances at the North Farm Operable Unit since no treatment would be
employed.
Information gained by EP A from the ground water monitoring program will
be used to evaluate the mobility of contaminants at the site. The toxicity
and volume of the contaminants will decrease due to natural attenuation
processes. Natural attenuation will achieve the same reductions as the
original remedy, only it will take longer to achieve these reductions. The
rate of reduction due to natural attenuation processes will be evaluated
during the ground water monitoring program. The originally selected
remedy is the only remedy which considers treatment.
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3.
Short-Term Effectiveness
Short-term effectiveness evaluates the length of time needed to implement
each segment of the alternatives. EP A considers the risks that a particular
activity may pose to site workers, nearby residents, or the local
environment. Short-term effectiveness involves the period of time needed
to achieve protection and considers any adverse impacts on human health
and the environment that may be posed during the construction and
implementation period until clean up goals are achieved.
As the amended remedy requires no construction or excavation activities,
the amended remedy would be more effective in the short term than the
previously selected remedy. The previously selected remedy employing
excavation, solidification and disposal would disturb the contaminated soils
which could potentially affect site workers. Worker exposure could
potentially occur through direct contact, ingestion or inhalation of
contaminated soil particles. Therefore, the amended remedy is more
effective in the short-term than the previously selected remedy.
4.
Implementability
EP A considers how difficult the alternative is to construct and operate, how
other government agencies and EP A will coordinate monitoring programs
and the availability of goods and services and personnel needed to
implement and manage the alternative. Implementability addresses the
technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the chosen
solution.
Both the original and selected remedies are readily implementable. The
amended remedy (institutional controls including deed restrictions, land use
restrictions and ground water monitoring), is more easily implemented than
the original remedy (excavation, solidification and disposal). In addition,
the amended remedy requires no additional construction activities and, as
such, it can be implemented within a short timeframe.
5.
Cost
EP A considers capital costs, operation and maintenance costs, and present
worth, which is the cost of the activities that will take place until the
remedial action is completed. Capital costs apply to activities such as
construction, land and site development, and disposal of waste materials.
Annual operation and maintenance costs are spent on activities such as on-
going operation of equipment, insurance and periodic site reviews.
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CERCLA requires that the EPA select a cost-effective alternative that
protects human health and the environment and meets other requirements
of the law. EPA has determined that the selected remedy is as protective
and is more cost effective than the original remedy for the North Farm
Operable Unit. Project costs are estimated to be less; specifically,
$403,000 for the original remedy versus $27,100 ($10,400 for the first year
[sample 3 ground water wells quarterly] plus costs for deed restrictions).
$15,300 is the Present Worth estimate for years 1-4 with semi-annual
sampling events, with each water sample collection and analysis cost
estimated to be $665 per sample with a 30% contingency included at an
8% interest rate. Costs for deed restrictions are estimated to be $1,454.
C. Modifying Criteria:
1. State Acceptance
The State of Iowa, through the IDNR, is supportive of the amended
remedy for the North Farm Operable Unit. The State of Iowa prefers the
amended remedy to the originally selected remedy.
2. Community Acceptance
EPA held a public comment period to allow the community to comment on
the preferred alternative as set forth in the Proposed Plan and the other
alternatives considered. Community response addresses the concerns of the
public regarding acceptance of a particular remedy. EPA has responded to
public comments received for consideration in the attached responsiveness
summary. The community was opposed to the original remedy for the
North Farm Operable Unit. Community response indicated that the public
did not perceive the contamination at the North Farm Operable Unit as
presenting any significant threat to human health or the environment.
In comparing the originally developed and selected North Farm Operable Unit
remedy with the amended remedy, EPA has determined that the original and amended
remedy meet the threshold criteria: overall protection of human health and the
environment and compliance with state and federal requirements.
The selected amended remedy for the North Farm Operable Unit presents the
better balance of tradeoffs, with respect to the primary balancing criteria, in particular
with respect to cost, implementability, and short-term effectiveness. While this amended
remedy does not meet the statutory preference for reduction of toxicity, mobility or
volume through treatment, EPA's reevaluation of the risks at the site has lead EPA to
determine that the levels of hazardous substances remaining at the site do not warrant
active treatment. For the modifying criteria of state and community acceptance, the
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amended alternative is preferred by both the state of Iowa and the community of
Kellogg. In the tradeoff and balancing of all nine criteria, the proposed remerty is EP A's
selected remedy.
MIDWEST MANUFACfURING OPERABLE UNIT
The following is a discussion of the nine criteria used by EP A for remedy
selection.
A.
Threshold Criteria:
1.
Overall Protection of Human Health and the Environment
EP A assesses the degree to which the alternatives would eliminate, reduce,
or control threats to public health and the environment through removal,
containment, and/or institutional controls. An alternative is normally
considered to be protective of human health if the excess cancer risk is
reduced to less than 1 in 1,000,000 (10-6) and risks do not pose non-
carcinogenic health risks (HI < 1).5
The contamination at the Midwest Manufacturing Operable Unit poses no
current risks to human health or the environment. Future risks can be
controlled by institutional controls, that is deed restrictions to prevent the
installation of a water supply well, and engineering controls, specifically, the
installation of a secure perimeter fence to prevent access to contaminated
soils. Monitoring of the quality of the ground water will assist EP A in
determining if this action continues to be protective of human health and
the environment.
2.
Compliance with all Applicable or Relevant and Appropriate State
and Federal Environmental Regulations
EP A assesses whether the remedial alternatives being evaluated would
comply with all applicable or relevant and appropriate requirements, called
ARARs, established by the state and federal government. The 1990 ROD
identified RCRA as relevant and appropriate for the contaminated soils
present at the Midwest Manufacturing Operable Unit. The amended ROD
leaves all soils in place, therefore, RCRA is not applicable to this action.
The original ROD identified the Clean Water Act (CW A) as an ARAR for
the ground water extraction and treatment system. The amended remedy
leaves all ground water in place, therefore the requirements of the CW A
5 The Hazardous Index rating does not exceed 1.
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are not ARARS. The original ROD identified Chapter 133 of the Iowa
Code as an ARAR and determined that "active" cleanup was neressary to
meet this ARAR. The state of Iowa has indicated that "passive" cleanup or
natural attenuation will meet the requirements of Chapter 133.
The selected amended remedy would comply with all federal and state
ARARs.
B.
Primary Balancing Criteria:
1.
Long-Term Effectiveness and Permanence
Long-term effectiveness and permanence refers to the ability of a remedy
to maintain reliable protection of human health and the environment over
time once clean up goals have been met. EP A has no evidence that the
levels of contamination at the site affect either human health or the
environment, therefore, the amended remedy is as protective of human
health and the environment as the original remedy. Since contamination
will remain on-site, EP A will conduct a 5 year review of this amended
remedy to determine if it remains effective in the long-term.
2.
Reduction of Toxicity, Mobility, or Volume Through Treatment
Section 121(b) of CERCLA states that remedial actions involving
treatment, which permanently and significantly reduce the volume, mobility
or toxicity of hazardous materials, are to be preferred over those not
involving such treatment. This evaluation criteria relates to the ability of a
remedial alternative to control or eliminate risks caused by the mobility,
toxicity or volume of hazardous material. The proposed remedy would
have limited impact on the toxicity, volume or mobility of the hazardous
substances at the Midwest Manufacturing Operable Unit since no
treatment would be employed.
Information gained by EP A from the ground water monitoring effort will
be used to evaluate the migration of contamination from the site. The
toxicity and volume of the contaminants will remain at the same level or
will be reduced due to natural attenuation. Natural attenuation will
achieve the same reductions as the original remedy, only it will take longer
to achieve these reductions. The rate of reduction due to natural
attenuation processes will be evaluated during the ground water monitoring
program. Information from the RI indicates that the contaminants remain
on-site and are not migrating off-site. The originally selected remedy is the
only remedy which considers treatment.
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3.
Short-Term Effectiveness
Short-term effectiveness evaluates the length of time needed to implement
each segment of the alternatives. EP A considers the risks that conducting
a particular activity may pose to site workers, nearby residents, or the local
environment. Short-term effectiveness involves the period of time needed
to achieve protection and considers any adverse impacts on human health
and the environment that may be posed during the construction and
implementation period until clean up goals are achieved.
The amended remedy would have short term risks during the installation of
the fence and any additional monitoring welles) needed. These elevated
levels of risks will be limited and can be addressed by the Health and
Safety Plan for all on-site workers involved in the field work. The
previously selected remedy employing installation of a cap and the ground
water extraction and treatment system would disturb the contaminated soils
which could potentially affect site workers. Worker exposure could
potentially occur through direct contact, ingestion or inhalation of
contaminated soil particles. Therefore, the amended remedy is more
effective in the short-term than the previously selected remedy.
4.
Implementability
EP A considers how difficult the alternative is to construct and operate, how
other government agencies and EP A will coordinate monitoring programs
and the availability of goods and services and personnel needed to
implement and manage the alternative. Implementability addresses the
technical and administrative feasibility of a remedy, including the
availability of materials and services needed to implement the chosen
solution.
Both the original and selected remedy are readily implementable. The
amended remedy (institutional controls including deed and access
restrictions, fencing and ground water monitoring), is more easily
implemented than the original remedy (capping of disposal cell area with
ground water extraction and treatment). In addition, the amended remedy
involves limited construction activities and, as such, it can be implemented
within a shorter timeframe.
s.
Cost
EP A considers capital costs, operation and maintenance costs, and present
worth, which is the cost of the activities that will take place until the
remedial action is completed. Capital costs apply to activities such as
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construction, land and site development, and disposal of waste materials.
Annual operation and maintenance costs are spent on activities such as on-
going operation of equipment, insurance and periodic site reviews.
CERCLA requires that the EP A select a cost-effective alternative that
protects human health and the environment and meets other requirements
of the law. EP A has determined that the selected remedy is as protective
as and is more cost effective than the original remedy for the Midwest
Manufacturing Farm Operable Unit. In a comparison based upon current
costs, the cost of the ground water extraction and treatment system has
risen due to the low-yielding aquifer and the subsequent increase in the
number of extraction wells the system would require.
Project costs for the implementation of the original remedy increased to
$1,091,531, (up from 1990 ROD estimate of $488,844). The amended
remedy is estimated at $118,530 (Alternative 1 in ROD issued September,
1990 plus monitoring of city supply wells (see figure 3) quarterly for the
first year which is 36 water samples at $665/sample or $31,100 with a 30%
contingency). Design, engineering and construction costs are estimated to
be approximately $47,000. Total present value of the monitoring costs for
years 2-5 of the project are estimated to be $40,400 estimated at 8%
interest. Fencing costs are estimated to be approximately $11,000 based
upon a cost of $20 per linear foot (including design cost) with a 30%
contingency. Deed restrictions are estimated to be $1454.
Cost estimates for each water sample collected and analyzed in support of
this ROD Amendment are derived from Appendix I of the Feasibility Study
for the Midwest Operable Unit, Midwest ManufacturingINorth Farm
Superfund site, Kellogg, Iowa dated August 23, 1990. A 30% contingency
was added to these costs. 8% interest was used for present value for all
future costs.
c.
Modifying Criteria:
1.
State Acceptance
The State of Iowa, through the IDNR, is supportive of the amended
remedy for the Midwest Manufacturing Operable Unit. The State of Iowa
prefers the amended remedy to the originally selected remedy.
2.
Community Acceptance
EP A held a public comment period to allow the community to comment on
the preferred alternative as set forth in the Proposed Plan and the other
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alternatives considered. EP A's responses to these comments are included
in the Responsiveness Summary section of this document.
Community response addresses the concerns of the public regarding
acceptance of a particular remedy. EP A offered the community an
opportunity to comment on the Proposed Plan for the Midwest
Manufacturing Operable Unit. The community was opposed to the original
remedy for the Midwest Manufacturing Operable Unit. Community
response indicated that the public did not perceive the Midwest
Manufacturing Operable Unit as presenting any significant threat to human
health or the environment.
In comparing the originally developed and selected Midwest Manufacturing
Operable Unit remedy with the amended remedy, EP A has determined that the original
and amended remedy meet the threshold criteria: overall protection of human health and
the environment and compliance with state and federal requirements..
The selected amended remedy for the Midwest Manufacturing Operable Unit
presents the better balance of tradeoffs, with respect to the primary balancing criteria, in
particular with respect to costs, implementability, and short-term effectiveness. While
this amended remedy does not meet the statutory preference for reduction of toxicity,
mobility or volume through treatment, EP A's reevaluation of the risks at the site has lead
EP A to determine that the levels of hazardous substances remaining at the site do not
warrant active treatment. For the modifying criteria of state and community acceptance,
the amended remedy is preferred. In the tradeoff and balancing of all nine criteria, the
proposed remedy is EP A's selected remedy.
VI.
STATUTORY DETERMINATIONS
NORTH FARM OPERABLE UNIT
o
GROUND WATER
Since the selected amended remedy and the original remedy are identical with
respect to ground water, no new statutory determinations are made herein.
o
SOILS
The EP A has determined, and the State of Iowa concurs, that the selected
amended remedy herein satisfies the statutory requirements specified in CERCLA
Section 121 which state that the selected remedy must protect human health and the
environment and comply with applicable or relevant and appropriate federal and state
requirements. The amended remedy meets the statue's further preference that the
remedy be cost-effective, utilize permanent solutions and alternative treatment
21
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technologies or resource recovery technologies to the maximum extent practicable.
While this amended remedy not meet the statute preference for remedies that employ
treatment that permanently and significantly reduce the volume, toxicity or mobility of
hazardous substances as a principal element, in the balance and tradeoffs, EP A finds it
to be the preferred remedy.
MIDWEST MANUFACTURING OPERABLE UNIT
o
GROUND WATER
The EP A has determined, and the State of Iowa concurs, that the selected
am(~nded remedy herein satisfies the statutory requirements specified in CERCLA
Section 121 which state that the selected remedy must protect human heaJth and the
environment and comply with applicable or relevant and appropriate federal and state
requirements. The amended remedy meets the statue's further preference that the
remedy be cost-effective, utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
While this amended remedy not meet the statute preference for remedies that employ
treatment that permanently and significantly reduce the volume, toxicity or mobility of
hazardous substances as a principal element, in the balance and tradeoffs, EP A finds it
to be the preferred remedy.
o
SOILS
The EP A has determined, and the State of Iowa concurs, that the selected
amended remedy herein satisfies the statutory requirements specified in CERCLA
Section 121 which state that the selected remedy must protect human health and the
environment and comply with applicable or relevant and appropriate federal and state
requirements. The amended remedy meets the statue's further preference that the
remedy be cost-effective, utilize permanent solutions and alternative treatment
technologies or resource recovery technologies to the maximum extent practicable.
While this amended remedy not meet the statute preference for remedies that employ
treatment that permanently and significantly reduce the volume, toxicity or mobility of
hazardous substances as a principal element, in the balance and tradeoffs, EP A finds it
to be the preferred remedy.
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RESPONSIVENESS SUMMARY
RECORD OF DECISION AMENDMENT
MIDWEST MANUFAcruRING/NORTH FARM SITE
NORm FARM OPERABLE UNIT
MIDWEST MANUFAcruRING OPERABLE UNIT
In accordance with CERCLA Section 117, a public comment period was held from
February 18, 1993 to March 19, 1993, to allow interested parties to comment on EP A's
proposed plan for the Record of Decision Amendment for the North Farm Operable
Unit and the Midwest Manufacturing Operable Unit at the Midwest
ManufacturingINorth Farm site, Kellogg, Iowa.
EP A offered to hold a public meeting if requested. No requests for such a
meeting were received.
EP A received a total of three written comments on the proposed plan; however,
only one of those was received during the public comment period. The Iowa
Department of Natural Resources (IDNR) requested that EPA modify the ground water
monitoring program proposed for each operable unit based upon the information
collected. EP A has modified the monitoring program in the following manner: On a
yearly basis, EP A and the State of Iowa will review the analytical results from the public
and private supply wells and from the monitoring wells to determine if any modifications
to the monitoring program are needed for the upcoming year. EP A and the State will
review the location of the wells tested and the quantity and identity of the contaminants
present. If the review indicates that the contamination is migrating in the direction of
the pubHc or private supply wells or off-site, additional monitoring well locations may be
sampled or a more frequent sampling effort may be implemented to verify the movement
of the contaminants or the threat posed to either the public water supply or a private
water supply. If the ground water samples are found to be at or below the MCLs for the
chemicals of concern at each of the operable units, then the sampling frequency will be
reduced. AIl public and private supply wells within one mile of the Midwest
Manufacturing Operable Unit will be tested quarterly for the first two years of
remediation.
23
-------
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•ly Tjgs^^iSL^ ^^^3*s-'i:::isrl^ "7 s—-ss5=
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Ur-fi^^ awJO^""
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^ \s?L^3^^ a.^'^^^.'
NOTE : INFORMATION OBTAINED
AMERICAN AUTOMOBILE ASSOCIATION
MAP OF IOWA. NEBRASKA. ig|f
SITE INDEX
MIDWEST MANUFACTURING/NORTH FARM SI
NORTH FARM OPERAILE UNIT
KELLOQQ. IOWA
«
Woociirarci—Clyde Consulta:
awoiDoars. AM onrnemmmL sor
SITE VICINITY MAP
MM. rr SOC B4R U/23/87
POOR QUA! -TV
O^GHsAL
-------
NORTH PANM OP0UOLE
APPROXIMATE
MIOWCST
OPEHAIL
INOTE: INFORMATION OBTAINED FROM usos
KILLOOO. IOWA QUAORANOLE. 1 8«0
TION R11W
:UAORANOLE
.OCAT1ON
i
K
2000
4000
MBWEST MANUFACTURING/NORTH PAMM
NORTH FARM OPERA1LI UNIT
KtLLOQQ. IOWA
Wbodimrd-Clyde Consuitf
SITE LOCATION
POOR CUAIJ
ORiGlNAL
-------
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POOR QUALITY
ORiGiNAL
-------
7 ABLE 1
CONT~~H~;":~T~ :~ r::~:C::~.N/HEAL~ RISK
GROUND '':~TER
Hellt
Blse
Dfssa 1 vea Total Actio
Cancen~rat'on :oncen~ra~ion Hazara Excosure Leve
Contaminant Levei Levei Index Pathwav ( uall
Cadmium NDeS ug/l) 19 ugi 1 -1 Ingestion 1B
~anQanese 8Z-140 ug/l 520-,:CO ug/l <1 I nges t; on 1700
'~,ui"E
~iATERIAL/C::=:7~"'lNATED SOIL
Bac~QrcunQ Hazard Ex~osure
Conce~tration Index ~!thwav
Hea 1 t!
Basel
Acti 01
Leve'
(mal Itc
Con~~r.n"ant
Concentration
Detect eo
Cadmium
0.67-830 mq/kq
0.67 mg/kg
>1
Ingestion of
vegetables
grewn i n
conUDn nl tea
soil
13
Cyanide
ND(0.C30)-i.~ mg/kg C.058 mg/kg
<1
Ingestion of
vegetacies
grown 1n
clJnuunnatea
son
N/A
NOTt!:
MIA - Not App1;cab1e
mg/kg - mi11igrams per Ki10gram
ug/l . micrograms per liter
NO = not detected at levels within ()
.
-------
7ABLE 2
SUMMARY :~ ~!SK ~SS~!S~ENT ~~!UL~~ ~OR
HUMAN ~x?aSUF.~ ~~ CADMIUM A~ 7~E
~IDWES; ~ANUFAC7~RING/NORTH FARM $!iE
NORTH FARM A~EA OPERABLE ~NIT
EXD~sure ?atnway
CD!:RfD Ratio for
Non~ar~inoae"'c Effec
~l&u!
Mu,
Can
Averaae
Case-
::ic:~:enui :~qest1cn cf ~:i i
<: . <
. ..
< . ,
. .
< . )1
.
::iq~~~~:n c~ Srounc ~dte~
:n9!!!~:n c~ ~eQetacies
Grown 1 n S:: ; i
. ~ors: :ase ~~!nario.
-------
TABLE 3
EXPOSURE SCENARIOS QUAJ^TTFJED AT THE MIDWEST SITE
Exposed
Population
Trespasser 1
Trespasser 2
Trespasser J
Trespasser 3
Trespasser *
Tresoasser «
Occupational
(Future)
Exposure Point
Waste Disposal
Trencft
Site
River Bank
N. Skunx River
Borrow Pit
(Manni
Borrow Pit
(Mann)
Future Site
Exposure Medium
Soil
Surface Soil
Soil
Sediment
Surface Witer
Sediment
Surface Soil Sludge
Grounawater
Exposure Rome
latestioo
Dermal Contact
lagesuoB
loiestioo
Dermal Contact
Ingestjon
Dermal Contact
Ingestion
Icgestion
Dermal Contact
Ingestion
Ingesnon
Ingestion
Tresaasscr 1 Qu.ld playing in the vuu disposal trenen.
Trespasser 2 Cu.Id pliyuig md n^ng • bicycle or all-terrain chicle on-iite.
Tresouacr 3 Oild vallcuuj am plrang alcnaj the nvcr bank end is the tores. Sonic Riv«r.
*
Qu.LJ playing is tfae bamw pit (saarao).
-------
TABLE 4
SUMMARY OF CARCINOGENIC RISK
Exposed
Population
Adult
Occupational M
(Future;
Adult
Occupational (b|
(Future;
Exposure
Point
Future Site
Future Site
Exposure
Medium
Soil
Groundwiter
Specific Contaminant
of Concern (c)
Arsenic
Beryllium
Vinyl Chloride
Arsenic
Beryllium
Vinyl Chloride
Exposure
Route
Intesnon
Ingestion
Cancer
Risk'"
6E-6
1E-3
1*1
(9)
Typically, cancer risk of I £-6 or lower are considered to be of no practical significance, wh
higner cancer risk levels may be cause for concern.
Adult occupational worker.
The chemicals of potential concern (Table 5) were evaluated in the risk assessment under eac
exposure scenario. Those contaminants identified u posing unacceptaole health risks a:
presented here.
-------
TABLE 5
CHEMICALS OF POTENTIAL CONCERN*
Aluminum
Antimony
Arsenic
Barium
Beryllium
Cadmium
Chromium
Cobalt
Iron
Lead
Manganese
Mercury
Nickel
Vanadium
Cyanide
Vinyl chloride
Carbon disulfide
1,2-Dichloroethene
2-Butanone
1,1,1-Trichloroethane
Trichloroethene
Tetrachloroethene
Toluene
Ethyl benzene
Xylene
Phenamhrene
• AJ identified in the baseline risk assessment.
-------
TABLE 6
SUMMARY OFSUBCHRONIC NONCARCINOGENIC HEALTH HAZARDS
Exposed
Population
Child w
Trespasser 1
Child M
Trespasser 2
Child <*
Trespasser 3
Child '"
Trespasser 4
Adult n
Occupational
Exposure
Point
Waste Disposal
Trench
Site
River Bank
N. Skunk River
Borrow Pit
(Mann)
Future Site
Exposure
Medium
Soil
Surface Soil
Soil
Sediment
Surface Water
Sediment
Surface Soil
Groundwater
Specific Contaminant
of Concern* *^
NA
NA
NA
NA
NA
NA
NA
NA
Antimony
Exposure
Route
Ingestion
Dermal Contact
Ingestion
Ingestion
Dermal Contact
Iniestion
Dermal Conuct
Total
Iniestion
Iniestion
Dermal Conuct
Ingejtion
Iniestion
Total
Haurc
Index
*
si
<"
*]
;!
:i
(" A Hazard Index of one (IE*0) or less indicates no noncarcinogenic health risks exist for thst
scenario.
ft! Chile! playing in the w«te disoosai trencn.
1:1 Child playing and riding a bicycle or all-terrain vehicle on-sne.
(
-------
TABLE 7
SUMMARY OF CHRONIC NONCARCINOGENJC HEALTH HAZARDS
Exposed
Population
Child w
Trespasser 1
Child M
Trespasser 2
Child (d>
Trespasser 3
Child (tl
Tressasser *
Adult ft
Occupational
Exposure
Point
Waate Disposal
Trench
Site
River Bank
N. Skunk River
Borrow Pit
(Marsh)
Future Site
Exposure
Medium
Soil
Surface Soil
Soil
Sediment
Surface Watei
Sediment
Surface Soil
Croundwater
Specific Contaminant
of Concern O
NA
NA
NA
NA
NA
NA
NA
NA
Antimony
Exposure
Route
Ingestion
Dermal Contact
Ingesuon
Ingestion
Dermal Contact
Ingestion
Dermal Contact
Total
Ingestion
Ingesuon
Dermal Contact
Ingestion
Ingestion
Total
Hazar.
Indei
;;
"
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